The SECURE 2.0 Act marked a significant step toward enabling more small business owners and employees to pursue retirement stability.
Outlined below is the status of our recordkeeping support for some key SECURE 2.0 provisions (sections). You can share this information with your clients ― whether they have an existing retirement plan or they’re considering starting one ― to help them take advantage of the benefits from this legislation.
For a better understanding of these provisions, including our perspective on the potential impacts, refer to SECURE 2.0 ― More of a good thing (PDF).
Provision |
Effective date |
Recordkeeping status |
|---|---|---|
Qualified disaster recovery distributions Section 331 (optional) |
Effective for disasters occuring on or after January 26, 2021 |
Ready to support |
Employer Roth contribution option Section 604 (optional) |
Effective for contributions made after December 29, 2022 |
Intend to support in 2025 We’re evaluating solutions based on IRS guidance. |
Terminal illness early distribution penalty tax exception Section 326 (optional) |
Distributions made after December 29, 2022 |
Ready to support |
Fewer notices for unenrolled employees Section 320 (optional) |
Plan years beginning after December 31, 2022 |
In progress We plan on developing a new notice template to assist plan sponsors in preparing the required participant notification for those who decide to take advantage of this change. We’re also evaluating our automated notice delivery process to potentially incorporate this notice type. |
Relaxed required minimum distribution (RMD) rules ― age and penalty adjustments Section 107 (mandatory) |
Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022 |
Ready to support |
Self-certification for hardship withdrawals Section 312 (optional) |
Plan years beginning in 2023 |
Intend to support in 2025 We’re developing a solution to accommodate plans that decide to offer self-certification hardship withdrawals. More information will be communicated on this process in the near future. |
Emergency Roth savings accounts Section 127 (optional) |
Plan years beginning after December 31, 2023 |
Evaluating We’re monitoring the demand for in-plan emergency savings accounts. Our early research and surveys indicate that there is not a high level of interest. |
Hardship distribution change for 403(b) plans Section 602 (optional) |
Plan years beginning after December 31, 2023 |
Ready to support We support hardship distributions from earnings on elective deferrals and from qualified non-elective contributions and qualified matching contributions, as well as earnings from these sources. |
Higher dollar limit for mandatory distributions Section 304 (optional) |
Distributions made after December 31, 2023 |
Ready to support |
Domestic abuse distributions Section 314 (optional) |
Distributions made after December 31, 2023 |
Ready to support |
Distributions for certain emergency expenses Section 115 (optional) |
Distributions made after December 31, 2023 |
Evaluating We’re evaluating solutions based on IRS guidance. |
RMD treatment of Roth amounts ― Roth balance exclusion Section 325 (mandatory) |
Taxable years beginning after December 31, 2023, but not to distributions which are required with respect to years beginning before January 1, 2024, but are permitted to be paid after such date |
Ready to support
|
Student loan payments as elective deferrals Section 110 (optional) |
Plan years beginning after December 31, 2023 |
In progress We’re evaluating what’s needed to facilitate student loan matching. Our existing functionality allows plan sponsors to remit matching contributions when they independently verify that student loan payments have been made. |
Required automatic enrollment and auto escalation Section 101 (mandatory) |
Plan years beginning after December 31, 2024 |
Ready to support |
Wider plan eligibility for part-time workers Section 125 (mandatory) |
Plan years beginning after December 31, 2024 |
Ready to support Note: This provision doesn’t supersede SECURE 1.0’s eligibility rules for 401(k) plans, so workers may qualify for plan eligibility under the three-year rule as soon as 2024 or the two-year rule in 2025. |
Higher catch-up contribution limit for ages Section 109 (optional) |
Plan years beginning after December 31, 2024 |
Ready to support |
Required Roth catch-up contributions for high-income earners Section 603 (mandatory) |
Taxable years beginning after 2025 |
Ready to support IRS guidance has delayed this requirement from 2024 to 2026. If your plan allows catch-up but not Roth contributions, we encourage you to add Roth contributions now and ensure that your payroll vendor is prepared for the change. Starting in 2026, we’ll offer warnings during payroll processing for participants age 50+ who are high earners and approaching the 402(g) contribution limit. We plan to have the ability to recharacterize pre-tax deferrals to Roth to further support this provision. |
Provision |
Effective date |
Recordkeeping status |
|---|---|---|
Qualified disaster recovery distributions Section 331 (optional) |
Effective for disasters occuring on or after January 26, 2021 |
Ready to support |
Employer Roth contribution option Section 604 (optional) |
Effective for contributions made after December 29, 2022 |
Intend to support in 2025 We’re evaluating solutions based on IRS guidance. |
Terminal illness early distribution penalty tax exception Section 326 (optional) |
Distributions made after December 29, 2022 |
Intend to support in 2025 |
Fewer notices for unenrolled employees Section 320 (optional) |
Plan years beginning after December 31, 2022 |
In progress We plan on developing a new notice template to assist plan sponsors in preparing the required participant notification for those who decide to take advantage of this change. |
Relaxed required minimum distribution (RMD) rules ― increased age triggering required beginning date Section 107 (mandatory) |
Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022 |
Ready to support |
Self-certification for hardship withdrawals Section 312 (optional) |
Plan years beginning in 2023 |
Intend to support in 2025 We’re developing a solution to accommodate plans that decide to offer self-certification hardship withdrawals. More information will be communicated on this process in the near future. |
Emergency Roth savings accounts Section 127 (optional) |
Plan years beginning after December 31, 2023 |
Evaluating We’re monitoring the demand for in-plan emergency savings accounts. Our early research and surveys indicate that there is not a high level of interest. |
Hardship distribution change for 403(b) plans Section 602 (optional) |
Plan years beginning after December 31, 2023 |
Ready to support We support hardship distributions from earnings on elective deferrals and from qualified non-elective contributions and qualified matching contributions, as well as earnings from these sources. |
Domestic abuse distribution Section 314 (optional) |
Distributions made after December 31, 2023 |
Intend to support in 2025 |
Distribution for certain emergency expenses Section 115 (optional) |
Distributions made after December 31, 2023 |
Available November 1, 2024 |
Higher dollar limit for mandatory distributions Section 304 (optional) |
Distributions made after December 31, 2023 |
In progress We’re in the process of updating our Automatic IRA agreement to reflect the higher limit and expect to support this new limit. |
RMD treatment of Roth amounts ― Roth balance exclusion Section 325 (mandatory) |
Taxable years beginning after December 31, 2023, but not to distributions which are required with respect to years beginning before January 1, 2024, but are permitted to be paid after such date |
Ready to support |
Student loan payments as elective deferrals Section 110 (optional) |
Plan years beginning after December 31, 2023 |
In progress We’re evaluating what’s needed to facilitate student loan matching. Our existing functionality allows plan sponsors to remit matching contributions when they independently verify that student loan payments have been made. |
Required automatic enrollment and auto escalation Section 101 (mandatory) |
Plan years beginning after December 31, 2024 |
Ready to support |
Wider plan eligibility for part-time workers Section 125 (mandatory) |
Plan years beginning after December 31, 2024 |
Ready to support
|
Higher catch-up contribution limit for ages Section 109 (optional) |
Taxable years beginning after December 31, 2024 |
Ready to support |
Required Roth catch-up contributions for high-income earners Section 603 (mandatory) |
Taxable years beginning after 2025 |
Ready to support Plans can add Roth deferrals or remove catch-up contributions at any time. In 2025, we will introduce the ability to recharacterize pre-tax deferrals to Roth to further support this provision. We encourage your clients to have a conversation with their payroll provider to ensure they’re prepared for Roth contributions and talk to their TPA about any necessary plan document amendments. |
Provision |
Effective date |
Recordkeeping status |
|---|---|---|
Relaxed required minimum distribution (RMD) rules Section 107 (mandatory) |
Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022 |
Ready to support |
Roth ― Employee deferrals Section 601 (optional) |
Taxable years beginning after December 31, 2022 |
Ready to support new SIMPLE IRA Plus plans. Existing SIMPLE IRA Plus plans need to amend the plan to offer Roth employee deferrals starting 1/1/25. Coming 1/1/25 for new SIMPLE IRA plans. Existing SIMPLE IRA plans need to amend the plan to offer Roth employee deferrals starting 1/1/25. In progress for SEP IRAs. We’re monitoring demand and evaluating solutions. |
Roth ― Employer contributions Section 601 (optional) |
Taxable years beginning after December 31, 2022 |
In progress We’re evaluating solutions based on IRS guidance. |
SIMPLE IRA contribution limit changes Section 117 (mandatory) |
Taxable years beginning after December 31, 2023 |
Ready to support |
SIMPLE IRA nonelective employer contributions Section 116 (optional) |
Taxable years beginning after December 31, 2023 |
Ready to support |
Replace SIMPLE IRA w/ Safe Harbor 401(k) plans during the year Section 332 |
Taxable years beginning after December 31, 2023 |
Ready to support |
Student Loans matching contributions Section 110 (optional) |
Taxable years beginning after December 31, 2023 |
Ready to support |
Higher catch-up contribution limit for ages Section 109 (optional) |
Taxable years beginning after December 31, 2024 |
Ready to support |